Chief Counsel's Written Determinations Issued from 200030000 to 200034999

Taxpayer-specific rulings or determinations are written memoranda furnished by the IRS National Office in response to requests by taxpayers under published annual guidelines. Technical advice memoranda are written memoranda furnished by the National Office of the IRS upon request of a district director or chief appeals officer pursuant to annual review procedures. Chief Counsel advice are written advice or instructions prepared by the Office of Chief Counsel and issued to field or service center employees of the IRS or Office of Chief Counsel.

It is important to note that pursuant to 26 USC § 6110(j)(3), such items cannot be used or cited as precedent.

200034039(PDF, 177K)	6/2/2000
This is in reply to your request for a ruling dated September 17, 1999, concerning the federal income tax consequences of the repayment of exempt loans under § 4975 of the Internal Revenue Code , and the treatment under § 415 of the Code of the allocation of the proceeds of a sale of stock held by Plan X to participants' accounts.
200034038(PDF, 152K)	5/31/2000
This is in response to a ruling request dated January 31, 2000, as supplemented by a letter dated May 15,2000, submitted on your behalf by your authorized representative, concerning the federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code , of certain contributions to Plan X.
200034037(PDF, 100K)	5/31/2000
This ruling is seeking the effects on your proposal to expand the geographical area in which you initially proposed to operate. Your prior operations were approved in an earlier ruling letter to you. Subsequent to that ruling you changed your legal structure from a trust to a corporation.
200034036(PDF, 109K)	5/31/2001
This is in reply to your ruling request of December 29, 1999. You have requested approval of a proposed set-aside of your income under the suitability test of § 4942(g)(2)(B)(i) of the Internal Revenue Code and § 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations.
200034035(PDF, 246K)	5/22/2000
This is in response to your ruling request of April 24, 2000, requesting advance approval of your scholarship program pursuant to § 4945(g) of the Internal Revenue Code. Our records show that you are exempt from federal income tax under § 501.
200034034(PDF, 250K)	5/31/2000
This is in response to your ruling request of February 10,2000, requesting advance approval of your grant procedures established pursuant to § 4945(g)(l) of the Internal Revenue Code.
200034033(PDF, 230K)	5/30/2000
A response to your ruling request dated May 12, 1999, concerning the federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code (Code), of certain contributions to Plans A, B, and C.
200034032(PDF, 500K)	5/30/2000
A response to ruling request dated May 12, 1999, concerning the federal income tax treatment, under § 414(h) (2) of the Internal Revenue Code (Code), of certain contributions to Plan B.
200034031(PDF, 319K)	5/30/2000
A ruling with respect to your § 242(b)(2) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) election.
200034030(PDF, 14K)	8/3/2000
Can a taxpayer authorize the Service to levy on a specific property of the taxpayer to collect taxes subject to an installment agreement and still retain his or her Collection Due Process rights under Internal Revenue Code § 6330.
200034029(PDF, 11K)	8/3/2000
Do the parents of a minor child who was kidnapped by a person not related to the child meet the support test for taking a dependency exemption for the child in the year of the kidnapping, if the parents provided the sole support for the child before the kidnapping, and the child is missing at the end of the year.
200034028(PDF, 24K)	8/3/2000
Recovery or Reversal of Erroneous Reparation Tax Credit Significant Service Center Advice
200034027(PDF, 10K)	8/7/2000
Whether the reporting requirements of § 6050I apply to payment for certain items of personal property, purchased at the same time and paid for with monetary instruments or a combination of currency and monetary instruments, whose individual prices are $10,000 or less, but aggregate in excess of $10,000.
200034026(PDF, 39K)	8/3/2000
Whether a state or local law enforcement agency in the State of Tennessee may qualify to receive an informant reward under § 7623 of the Internal Revenue Code.
200034025(PDF, 23K)	8/14/2000
This Technical Assistance is in response to your request for assistance dated December 15, 1999, regarding the tax treatment of state payments made to individuals and businesses of North Carolina who suffered losses due to the flood damage caused by Hurricane Floyd.
200034024(PDF, 39K)	8/18/2000
You request a ruling that premiums received by taxpayer on policies of insurance or reinsurance of United States risks are exempt from the insurance excise tax imposed by § 4371 of the Internal Revenue Code of 1986.
200034023(PDF, 6.8K)	8/3/2000
This letter responds to a letter dated February 7, 2000, and subsequent correspondence submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200034022(PDF, 9.8K)	8/3/2000
This is in reply to your letter dated January 21, 2000, and subsequent correspondence, requesting a ruling on the classification of Trust as a liquidating trust under § 301.7701-4(d) of the Procedure and Administration Regulations.
200034021(PDF, 20K)	8/14/2000
This letter is in response to your letter dated November 15, 1999, requesting: (1) a ruling that the severance of Trust 2 into two separate trusts pursuant to § 26.2654-1(b)(1) of the Generation Skipping Transfer Tax Regulations will be recognized for GST tax purposes; and (2) an extension of time under § 301.9100 of the Procedure and Administration Regulations to make a reverse Qualified Terminable Interest Property (QTIP) election under § 2652 of the Internal Revenue Code.
200034020(PDF, 35K)	8/14/2000
This letter responds to a letter dated May 24, 1999, and subsequent correspondence, submitted on behalf of Company A by its authorized representative, requesting rulings under § 29 of the Internal Revenue Code.
200034019(PDF, 14K)	8/14/2000
This letter responds to a letter dated December 1, 1999, and subsequent correspondence, submitted by A's authorized representative on behalf of A, requesting certain rulings under § 664 of the Internal Revenue Code concerning a proposed charitable remainder unitrust (CRUT).
200034018(PDF, 7.2K)	8/14/2000
This letter responds to a January 20, 2000 letter that X's authorized representative submitted on behalf of X concerning relief under § 1362(b)(5) of the Internal Revenue Code.
200034017(PDF, 9.0K)	8/3/2000
This letter responds to a January 20, 2000 ruling request and subsequent correspondence submitted on behalf of X by X's authorized representative requesting a ruling that X's rental income will not constitute passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code.
200034016(PDF, 6.7K)	8/3/2000
This letter responds to your January 24, 2000 letter and subsequent correspondence, concerning relief under § 1362(b)(5) of the Internal Revenue Code.
200034015(PDF, 12K)	8/3/2000
This is in response to your letter of December 1, 1999, requesting a ruling concerning the application of § 2601 of the Internal Revenue Code to a proposed renunciation of interests in a trust established for the benefit of L.
200034014(PDF, 8.3K)	8/14/2000
This letter responds to your September 23, 1999 request for a private letter ruling, submitted on behalf of X, requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal income tax purposes under § 301.7701-3(c).
200034013(PDF, 28K)	8/14/2000
This is in response to your letter of September 16, 1999, requesting rulings under § 280G of the Internal Revenue Code.
200034012(PDF, 49K)	8/14/2000
We reply to your November 2, 1999 request for rulings on certain federal income tax consequences of a series of transactions.
200034011(PDF, 8.0K)	8/3/2000
This responds to a letter dated April 25, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200034010(PDF, 72K)	8/25/2000
Whether the subject financing arrangement falls within the definition of a "fast-pay arrangement," as defined in Treasury Regulation § 1.7701(l)-3(b). If so, whether the application of Treas. Reg. § 1.7701(l)-3 has an immediate effect on the current examination cycle.
200034009(PDF, 43K)	8/14/2000
This letter responds to your request, dated August 30, 1999, that we rule on certain tax consequences of the sale of the Plant from Sellers to Taxpayer/Buyer.
200034008(PDF, 43K)	8/14/2000
This letter responds to your request, dated August 30, 1999, and supplemental information, that we rule on certain tax consequences of the sale of the Plant from Seller to Buyer.
200034007(PDF, 42K)	8/14/2000
This letter responds to your request, dated August 30, 1999, that we rule on certain tax consequences of the sale of the Plant from Seller to Taxpayer/Buyer.
200034006(PDF, 9.6K)	8/3/2000
This responds to your request, dated January 10, 2000, requesting permission to revoke elections under § 528 of the Internal Revenue Code for the taxable years ending Date 1 and Date 2.
200034005(PDF, 22K)	8/3/2000
The Taxpayer is requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(2) of the Income Tax Regulations as the prior schedule of ruling amounts continued only through calendar year X.
200034004(PDF, 32K)	8/3/2000
Whether, for purposes of apportioning interest expense, Corp A may use restated financial earnings for pre-1987 tax years in computing the adjusted basis in stock of its controlled foreign corporations under § 1.861-12T(c)(2) of the Temporary Income Tax Regulations where the restatement of prior year earnings was permitted, but not mandated, under revised guidelines issued by the Financial Accounting Standards Board in 1987.
200034003(PDF, 45K)	8/14/2000
Whether supplier refunds received by Taxpayer, primarily a natural gas distribution utility, from its upstream suppliers is income in the year the refunds were mandated by order of the Federal Energy Regulatory Commission (FERC) or whether such refunds can be excluded from income because the amounts of the refund must be passed on to Taxpayer's customers.
200034002(PDF, 32K)	8/14/2000
This letter responds to your request, dated August 24, 1999, that we rule on certain tax consequences of the sale of the Plant from Seller to Buyer.
200034001(PDF, 17K)	8/14/2000
Can an unenrolled return preparer with a valid Power of Attorney sign an appeal of a rejected offer in compromise (OIC) on behalf of a taxpayer? Is the statute of limitations for collection set forth in Internal Revenue Code § 6502 suspended as a result of such an appeal?
200033050(PDF, 210K)	5/25/2000
A ruling dated December 29, 2000, from your authorized representative requesting a series of rulings on your behalf regarding the tax consequences associated with the affiliation agreement described below.
200033049(PDF, 423K)	5/16/2000
Rulings concerning a proposed transaction under § 501 (c)(3) and 511-513 of the Internal Revenue Code. Specifically, X requests us to rule with respect to the tax consequences attendant to its proposed sale of burial caskets.
200033048(PDF, 439K)	5/23/2000
Request for several letter rulings under § 72(t) 121 of the Internal Revenue Code.
200033047(PDF, 69K)	5/22/2000
This is in response to your request for a ruling dated July 8.1997, submitted by your authorized representative in which rulings are requested under § 404(k) and 3402, 3111, and 4975 of the Internal Revenue Code of 1988 (the "Code") with respect to amendments to Plan X.
200033046(PDF, 274K)	4/27/2000
Issues: (1) Whether the provision of services under Plan B where the medical providers are compensated on either a discounted fee-for-service basis with no withholds or under a point of service arrangement is commercial type insurance as described in § 501(m)(3) of the Code. (2) Whether the provision of services under Plan B is an insubstantial part of X's activities and would be subject to unrelated business income tax. 3. Whether the unrelated business income tax would be calculated under subchapter L rather than § 51.
200033045(PDF, 12K)	8/18/2000
Issue: Whether the procedure outlined in TEBB # 99375, which directs service centers to disallow duplicate dependent exemptions claimed on delinquent original returns reflecting married filing separate or head of household filing status, conflicts with
200033044(PDF, 25K)	8/18/2000
Issue: May the Service redact certain portions of the description of the records sought in the copies of the summons given to persons entitled to notice of the summons under § 7609(a)?
200033043(PDF, 24K)	8/18/2000
Taxpayers in general have argued two theories: (1) that the payments were entirely excludible from income under § 104(a)(2) as damages on account of personal injuries or sickness, and (2) that the payments were nonqualified deferred compensation to which FICA tax applied in the year the compensation was earned, not in the year it was received. § 3121(v)(2).
200033042(PDF, 12K)	8/18/2000
March 23, 2000 request for a supplement to the letter ruling dated June 30, 1999 (the "Prior Letter Ruling") (PLR-104542-99/199939040).
200033041(PDF, 15K)	8/18/2000
January 10, 2000, requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file elections. The extension is being requested by Parent (Parent is the common parent of the consolidated group of which Purchaser is a member.
200033040(PDF, 8K)	8/18/2000
September 22, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to make elections under § 1.884- 2T(d)(4) for Year One.
200033039(PDF, 6K)	8/18/2000
March 10, 2000, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200033038(PDF, 24K)	8/18/2000
Issue: Whether the Commissioner may reject a taxpayer's offer in compromise on the basis that a professional corporation wholly-owned by the taxpayer has failed to come into compliance with the filing and payment requirements of the Internal Revenue Service.
200033037(PDF, 19K)	8/18/2000
January 10, 2000 request for rulings on certain federal income tax consequences of a proposed transaction.
200033036(PDF, 9K)	8/18/2000
January 11, 2000, submitted on behalf of X, requesting a ruling that rents received by X will not constitute "passive investment income" within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code.
200033035(PDF, 28K)	8/18/2000
August 26, 1999, and subsequent correspondence dated January 24, 2000 and May 4, 2000, submitted on behalf of X and HLP, requesting rulings under §§ 708 and 42 of the Internal Revenue Code.
200033034(PDF, 16K)	8/18/2000
February 1, 2000, on the federal income tax consequences of a proposed transaction concerning § 355 of the Internal Revenue Code. We received additional information in letters dated March 27, April 3, and May 8, 2000.
200033033(PDF, 32K)	8/18/2000
August 26, 1999, and subsequent correspondence dated January 24, 2000 and May 4, 2000, submitted on behalf of X and HLP, requesting rulings under §§ 7701, 708, and 42 of the Internal Revenue Code.
200033032(PDF, 32K)	8/18/2000
August 26, 1999, and subsequent correspondence dated January 24, 2000 and May 4, 2000, submitted on behalf of X and HLP, requesting rulings under §§ 7701, 708, and 42 of the Internal Revenue Code.
200033031(PDF, 63K)	8/18/2000
December 14, 1999, in which rulings are requested as to the federal income tax consequences of a propose transaction. Additional information was submitted in letters dated March 21, March 24, March 31, April 6, April 10, and April 13, 2000.
200033030(PDF, 28K)	8/18/2000
August 26, 1999, and subsequent correspondence dated January 24, 2000 and May 4, 2000, submitted on behalf of X and HLP, requesting rulings under §§ 708 and 42 of the Internal Revenue Code.
200033029(PDF, 23K)	8/18/2000
January 12, 2000 request for rulings on certain federal income tax consequences of a proposed transaction.
200033028(PDF, 6K)	8/18/2000
December 13, 1999, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200033027(PDF, 24K)	8/18/2000
February 4, 2000, submitted on your behalf by your authorized representative, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200033026(PDF, 24K)	8/18/2000
February 4, 2000, submitted on your behalf by your authorized representative, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200033025(PDF, 24K)	8/18/2000
February 4, 2000, submitted on your behalf by your authorized representative, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200033024(PDF, 24K)	8/18/2000
February 4, 2000, submitted on your behalf by your authorized representative, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200033023(PDF, 24K)	8/18/2000
February 4, 2000, submitted on your behalf by your authorized representative, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200033022(PDF, 30K)	8/18/2000
December 21, 1999. The Taxpayer is requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(2) of the Income Tax Regulations as the prior schedule of ruling amounts continued only through calendar year The Taxpayer was previously granted a revised schedule of ruling amounts on August 10, 1994. Information was submitted pursuant to § 1.468A-3(h)(2).
200033021(PDF, 31K)	8/18/2000
December 21, 1999. The Taxpayer is requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(2) of the Income Tax Regulations as the prior schedule of ruling amounts continued only through calendar year 1998. The Taxpayer was previously granted a revised schedule of ruling amounts on July 12, 1994.
200033020(PDF, 14K)	8/18/2000
A request for an extension of time on behalf of Taxpayer to make a late election to treat capital gains as investment income under § 163(d)(1) and 163(d)(4)(B) of the Internal Revenue Code for Year 1.
200033019(PDF, 31K)	8/18/2000
December 22, 1999. The Taxpayer is requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(2) of the Income Tax Regulations as the prior schedule of ruling amounts continued only through calendar year The Taxpayer was previously granted a revised schedule of ruling amounts on July 12, 1994. Information was submitted pursuant to § 1.468A-3(h)(2).
200033018(PDF, 11K)	8/18/2000
January 26, 2000, as well as subsequent correspondence, submitted on behalf of Company, requesting a ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. Company represents the following facts.
200033017(PDF, 16K)	8/18/2000
March 16, 2000, and subsequent correspondence, submitted on behalf of Partnership requesting a private letter ruling that will waive for the Project the 10-year holding period requirement for existing buildings of § 42(d)(2)(B)(ii) of the Internal Revenue Code, under the authority of the exception for the acquisition of certain federally-assisted buildings provided in § 42(d)(6)(A)(i).
200033016(PDF, 40K)	8/18/2000
March 15, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200033015(PDF, 26K)	8/18/2000
January 31, 2000, and prior correspondence, requesting rulings on the income and gift tax consequences of a reformation of Trust 1.
200033014(PDF, 14K)	8/18/2000
November 5, 1999, and subsequent correspondence, requesting rulings under § 3508 of the Internal Revenue Code. In particular, a ruling was requested that certain real estate brokers ("subject brokers") will not be considered employees by reason of § 3508.
200033013(PDF, 20K)	8/18/2000
November 22, 1999, submitted on behalf of Personal Representatives of Estate, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a "reverse" qualified terminable interest property (QTIP) election under § 2652(a)(3) of the Internal Revenue Code with respect to Trust C-1 created under Will.
200033012(PDF, 59K)	8/18/2000
Issue: Whether Taxpayer made an irrevocable election under § 168 to use the straight-line or 150-percent declining balance method of depreciation rather than the 200-percent declining balance method of depreciation for 5-year property placed in service in Years 1 through 6.
200033011(PDF, 30K)	8/18/2000
Response to a request submitted on the behalf of Company by its authorized representatives for rulings concerning Company's group term life insurance program.
200033010(PDF, 7K)	8/18/2000
November 3, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200033009(PDF, 7K)	8/18/2000
November 30, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200033008(PDF, 11K)	8/18/2000
August 2, 1999, written on behalf of X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c).
200033007(PDF, 20K)	8/18/2000
September 17, 1999, requesting a ruling that the proposed modification of Trust 1, Trust 2, and Trust 3 ("Trusts") will not cause the Trusts to be subject to the Generation-Skipping Transfer tax imposed by § 2601 of the Internal Revenue Code.
200033006(PDF, 42K)	8/18/2000
This Field Service Advice responds to your request for advice which was processed on February 9, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200033005(PDF, 30K)	8/18/2000
The purpose of this memorandum is to provide guidance to Counsel attorneys regarding new § 6501(c)(4)(B) of the Internal Revenue Code, as enacted by § 3461(b) of the IRS Restructuring and Reform Act of 1998 (RRA 98).
200033004(PDF, 22K)	8/18/2000
Issues: (1) For purposes of the special rule for stock in § 1092(d)(3)(B)(i)(II) of the Internal Revenue Code, does § 1.1092(d)-2(a) of the Income Tax Regulations apply to provide that the phrase "substantially similar or related property" is defined in § 1.246-5 when that phrase is applied retroactively under the effective date rule in § 1.1092(d)-2(b)(2) (and the phrase is not defined by the "mimics" standard in § 1.1092(d)-2(b)(2))? (2) § 1092(c)(4)(A) of the Internal Revenue Code provides an exception from straddle treatment for offsetting positions consisting of qualified covered call options and the optioned stock. Taxpayer holds a portfolio of stocks for which Taxpayer has sold listed call options on certain of the stocks in the portfolio which would be qualified covered call options under § 1092(c)(4)(A) but for the possible existence of a larger straddle. Taxpayer has hedged against general market risk by purchasing listed put options on S&P 500 index futures contracts. The portfolio does not satisfy the "substantial overlap" test of § 1.246-5 with respect to the put options. Is the determination whether the put options create a larger straddle with respect to the call options and the optioned stock made on a stock-by-stock basis?
200033003(PDF, 43K)	8/18/2000
January 14, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200033002(PDF, 39K)	8/18/2000
Issues: (1) Whether a raised floor installed during the initial construction of an office building to facilitate the installation of computer systems is personal property under Internal Revenue Code § 168 or a structural component of a building? (2) If the raised floor is personal property under I.R.C. § 168, what is the appropriate recovery period? (3) Should Rev. Rul. 74-391, 1974-2 C.B. 9 be reconsidered in light of changes in the business environment since its issuance?
200033001(PDF, 38K)	8/18/2000
The claim for damages allege that the Service recklessly or intentionally violated the provisions of Internal Revenue Code §§ 7214, 6304, 6331(d), and 6301 when it collected late filing penalties from investors in A who did not settle their A-related tax liabilities with the Service, and by transferring payments made on behalf of one partnership to the account of another partnership.
200032051(PDF, 474K)	5/16/2000
A ruling regarding grant-making procedures, under § 4945(g) of the Internal Revenue Code.
200032050(PDF, 385K)	5/16/2000
A ruling regarding the effect of a proposed transaction in which you will lease a portion of a facility you purchased with borrowed funds to B.
200032049(PDF, 160K)	5/15/2000
A letter ruling concerning whether Plan X is a governmental plan as defined in § 414(d) of the Internal Revenue Code and whether Plan X meets the requirements of § 403(b) of the Code.
200032048(PDF, 752K)	5/16/2000
A ruling concerning whether Plan X meets the requirements of § 403(b) of the Internal Revenue Code , and whether Plan X is a governmental plan as defined in § 414(d) of the Code.
200032047(PDF, 242K)	5/17/2000
A ruling regarding approval of a proposed set-aside of income under the suitability test of § 4942(g)(2)(B)(i) of the Internal Revenue Code and § 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations.
200032046(PDF, 340K)	5/15/2000
This is in response to a letter from your authorized representative requesting a series of rulings on your behalf regarding the tax consequences.
200032045(PDF, 355K)	5/15/2000
This is in response to the in which you, through your authorized representative, request several letter rulings under § 408(d) of the Internal Revenue Code.
200032044(PDF, 409K)	5/15/2000
This is in response to the in which you, through your authorized representative, request several letter rulings under § 408(d) and 403(b)(lO) of the Internal Revenue Code.
200032043(PDF, 215K)	5/15/2000
This is in response to M's request for a ruling under. § 4941 of the Internal Revenue Code submitted by M's legal representative. M has requested a ruling that the terms of a compromise agreement between parties named in decedent's will, and the codicil thereto, will not constitute an act of self-dealing as described in § 4941 of the Code.
200032042(PDF, 34K)	8/11/2000
Issues: What procedures should be followed in the following situations, and how does the answer differ depending on whether the error was detected before the refund was sent? (1) The Service Center initially determines that the tax reported on the return is too high, but then determines in Notice Review that the tax originally reported on the return was correct. (2) The Notice Review function determines that not only was the initial determination of a lower tax incorrect, but the correct tax exceeds the amount reported on the return. (3) Notice Review determines that the initial determination was incorrect, but the correct tax is still lower than the amount reported on the return.
200032041(PDF, 25K)	8/11/2000
Issue: Are the following flood relief payments gross income to the recipient upon which information reporting is required under § 6041 of the Internal Revenue Code: payments to farmers and commercial fishermen for structure and equipment losses and supplemental payments to farmers to assist in restoring farmlands to usable areas and to restore the use of best management practices?
200032040(PDF, 35K)	8/11/2000
Issue: Whether the notice of intent to levy required by § 6331(d) must be issued to the corporation rather than a person holding a power of attorney when the corporation has authorized a person to represent the corporation.
200032039(PDF, 9K)	8/11/2000
September 29, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2) for the losses incurred by Subsidiaries for the tax years in issue.
200032038(PDF, 8K)	8/11/2000
October 13, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, effective for the tax year beginning on Date A.
200032037(PDF, 36K)	8/11/2000
March 7, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200032036(PDF, 10K)	8/11/2000
January 26, 2000, submitted by A's authorized representative requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200032035(PDF, 10K)	8/11/2000
November 17, 1999, requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200032034(PDF, 14K)	8/11/2000
February 23, 2000, concerning the taxability of certain crane-carrying truck chassis under § 4051(a)(1) of the Internal Revenue Code.
200032033(PDF, 15K)	8/11/2000
January 18, 2000, and subsequent correspondence submitted by you as X's authorized representative on behalf of X, requesting relief under § 1362(f) of the Internal Revenue Code.
200032032(PDF, 10K)	8/11/2000
August 31, 1999, on behalf of A, requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200032031(PDF, 8K)	8/11/2000
November 11, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, effective for the tax year beginning on Date A.
200032030(PDF, 9K)	8/11/2000
November 2, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2) for Tax Year One.
200032029(PDF, 9K)	8/11/2000
December 28, 1999, and subsequent correspondence, written on behalf of X by its authorized representative, requesting that the Service grant X an extension of time to make an election under § 301.7701-3(c) of the Procedure and Administration Regulations.
200032028(PDF, 14K)	8/11/2000
February 25, 2000, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to sever a marital trust (Residuary Trust) into an Exempt Marital Trust and a Nonexempt Marital Trust under § 26.2652-2(c) of the Generation-Skipping Transfer Tax (GSTT) Regulations.
200032027(PDF, 11K)	8/11/2000
December 29, 1999, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code.
200032026(PDF, 26K)	8/13/2000
April 25, 2000 letter requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Parent (as common parent of the consolidated group of which Sub 1, Sub 2, and Sub 3 are members) to file an election.
200032025(PDF, 12K)	8/11/2000
December 16, 1999 ruling request submitted on behalf of X by X's authorized representative requesting a ruling that X's rental income will not constitute "passive investment income" within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code.
200032024(PDF, 26K)	8/11/2000
April 25, 2000 letter requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Parent (as common parent of the consolidated group of which Sub 1, Sub 2, and Sub 3 are members) to file an election.
200032023(PDF, 7K)	8/11/2000
January 18, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200032022(PDF, 7K)	8/11/2000
December 10, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200032021(PDF, 7K)	8/11/2000
November 2, 1999, and subsequent correspondence, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200032020(PDF, 7K)	8/11/2000
January 10, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200032019(PDF, 10K)	8/11/2000
January 4, 2000 request that we supplement our letter ruling of January 12, 1999 (the "Prior Letter Ruling") and supplemental letter ruling of April 28, 1999 (together, the "Prior Letter Rulings"). Capitalized terms retain the meanings originally assigned them.
200032018(PDF, 13K)	8/11/2000
February 7, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code.
200032017(PDF, 24K)	8/11/2000
December 22, 1999, submitted by your authorized representative requesting rulings under § 280G of the Internal Revenue Code. Specifically, the letter requests rulings, under the facts outlined below, that the Exchange Value related to vested, nonqualified options does not constitute a parachute payment and that, with regard to the unvested options, the parachute payment is determined under § 1.280G-1, Q&A 24(c), of the proposed regulations, taking into account the Exchange Ratio.
200032016(PDF, 25K)	8/11/2000
April 25, 2000 letter requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Parent (as common parent of the consolidated group of which Sub 1, Sub 2, and Sub 3 are members) to file an election.
200032015(PDF, 11K)	8/11/2000
November 30, 1999, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an allocation of Grantor's remaining Generation-skipping Transfer Tax exemption to three irrevocable trusts.
200032014(PDF, 43K)	8/11/2000
September 23, 1999 request for rulings on certain federal income tax consequences of a proposed (and partially undertaken) transaction.
200032013(PDF, 31K)	8/11/2000
Issue: May a taxpayer who is an "eligible individual," as defined in § 32(c)(1)(A) of the Internal Revenue Code, for a taxable year and who otherwise meets the requirements of § 32 of the Code but who does not have an SSN that meets the requirements of § 32(m) during the taxable year claim the EIC for the taxable year if the taxpayer is issued an SSN that meets the requirements of § 32(m) after the close of the taxable year?
200032012(PDF, 16K)	8/11/2000
March 13, 2000, and prior correspondence, in which you requested a ruling concerning the generation-skipping transfer tax consequences of a proposed division of two trusts.
200032011(PDF, 17K)	8/11/2000
March 13, 2000, and prior correspondence, in which you requested a ruling concerning the generation-skipping transfer tax consequences of a proposed division of two trusts.
200032010(PDF, 20K)	8/11/2000
December 20, 1999, and subsequent correspondence, requesting a ruling that transfers of property to Charity A and other charitable organizations pursuant to a Compromise Agreement qualify for the estate tax charitable deduction under § 2055 of the Internal Revenue Code.
200032009(PDF, 13K)	8/11/2000
December 23, 1999 request for rulings on certain federal income tax consequences of a proposed transaction.
200032008(PDF, 38K)	8/11/2000
Issue: Whether, after issuance of the preferred stock in USSub1 on date a, USParent must include USSub1 in determining its foreign tax credit limitation on an affiliated group basis.
200032007(PDF, 21K)	8/11/2000
In reply to the request for a ruling concerning whether the nonqualified pension plans maintained for the benefit of employees of X and Z constitute "exempt governmental deferred compensation plans" for purposes of § 3121(a)(5)(E) and 3121(v)(3) of the Internal Revenue Code ("the Code").
200032006(PDF, 21K)	8/11/2000
In reply to the request for a ruling concerning whether the nonqualified pension plans maintained for the benefit of employees of X and Z constitute "exempt governmental deferred compensation plans" for purposes of § 3121(a)(5)(E) and 3121(v)(3) of the Internal Revenue Code ("the Code").
200032005(PDF, 26K)	8/11/2000
October 20, 1999 letter requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Parent (as common parent of the consolidated group of which Sub 1, Sub 2, and Sub 3 are members) to file an election.
200032004(PDF, 35K)	8/11/2000
Issue: Whether the Service can levy upon and collect the assets in a taxpayer's 401(k) pension plan when the taxpayer has an immediate right to elect normal retirement benefits, but instead, elects to defer retirement.
200032003(PDF, 24K)	8/11/2000
January 10, 2000. You ask that we pre-review your memorandum to Acting Chief, Special Procedures Branch, Indiana District.
200032002(PDF, 42K)	8/11/2000
Issues: (1) Does the Excise Tax on foreign reinsurance under Internal Revenue Code § 4371(3) apply to reinsurance covering items shipped outside the United States. (2) Whether a claim for refund may be filed by a reinsurer which did not remit the tax under I.R.C. § 4371 to the Service.
200032001(PDF, 29K)	8/11/2000
Issue: Whether B and C are liable for taxes associated with a noneconomic REMIC residual interest.
200031060(PDF, 206K)	8/26/1999
A ruling regarding tax consequences to participants on amounts paid for, and amounts paid to Plan X under a long-term disability insurance policy (LTDI).
200031059(PDF, 301K)	5/19/2000
This letter is in response to your request, dated November 21, 1999, for a ruling that distributions from your individual retirement accounts (IRAs) would qualify as part of a series of substantially equal periodic payments, provided for under § 72(t)(2)(A)(iv) of the Internal Revenue Code.
200031058(PDF, 418K)	5/11/2000
This letter is in response to your request, dated December 12, 1999, for a ruling concerning whether proposed distributions Tom your individual retirement account (IRA) would qualify as part of a series of substantially equal periodic payments, provided for under § 72(t)(2)(A)(iv) of the Internal Revenue Code.
200031057(PDF, 261K)	5/11/2001
Ruling in which the federal income tax consequences of a proposed transfer of assets from A to certain other foundations supporting constituent institutions of Q was sought.
200031056(PDF, 166K)	5/10/2000
A ruling on the federal tax consequences of certain transactions involving an individual retirement arrangement (IRA).
200031055(PDF, 599K)	5/10/2000
Request sent by your authorized representative for rulings with respect to the excise tax applicable to a reversion of surplus assets to the Company on account of the termination of the Salaried Plan and the transfer of a portion of the surplus to the 401(k) Plan.
200031054(PDF, 391K)	5/19/2000
A reference requesting advance approval of grant procedures under § 4945(g) of the Internal Revenue Code.
200031053(PDF, 321K)	5/9/2000
This letter responds to X's request dated October 21, 1999 for rulings that X's proposed Grant will further its exempt purposes under § 501(c)(3) of the Internal Revenue Code and will comply with requirements under chapter 42.
200031052(PDF, 100K)	5/8/2000
This is in response to your letter requesting rulings regarding certain federal tax consequences.
200031051(PDF, 10K)	8/4/2000
Requesting a ruling that X be granted an extension of time in which to elect to treat its subsidiary W as a qualified subchapter S subsidiary (QSub).
200031050(PDF, 16K)	8/4/2000
March 17, 2000, in which rulings were requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted in a letter dated April 17, 2000.
200031049(PDF, 27K)	8/4/2000
November 8, 1999, and subsequent correspondence submitted on behalf of P1, P2, P3, P4, P5, P6, P7, P8, S1, S2, S3, S4, S5, S6, S7, S8, S9, and S10, by their authorized representative requesting certain rulings relating to the master-feeder investment fund structure between P3 through P8 (the "Series") and S1 through S10 (the "Funds").
200031048(PDF, 8K)	8/4/2000
November 24, 1999, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200031047(PDF, 44K)	8/4/2000
December 21, 1999 ruling request and subsequent correspondence submitted on behalf of X by X s authorized representative concerning § 1362(d)(2) of the Internal Revenue Code and concerning an extension of time in which to elect to treat Company 8 as a qualified subchapter S subsidiary under § 1361(b)(3)(B).
200031046(PDF, 12K)	8/4/2000
December 31, 1999, and subsequent correspondence submitted by you as X's authorized representative on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code.
200031045(PDF, 14K)	8/4/2000
December 27, 1999, that you submitted on behalf of Entity.
200031044(PDF, 8K)	8/4/2000
April 6, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200031043(PDF, 8K)	8/4/2000
March 23, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200031042(PDF, 20K)	8/4/2000
February 14, 2000 request for rulings on the federal income tax consequences of a proposed transaction.
200031041(PDF, 27K)	8/4/2000
August 18, 1999, and other submissions in which your authorized representatives requested rulings regarding the effect of the consolidation of three trusts for federal income, estate, gift, and generation-skipping transfer tax purposes.
200031040(PDF, 20K)	8/4/2000
February 14, 2000 request for rulings on the federal income tax consequences of a proposed transaction.
200031039(PDF, 25K)	8/4/2000
December 22, 1999, requesting rulings as to certain federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated March 27, 2000, and April 19, 2000.
200031038(PDF, 17K)	8/4/2000
January 13, 2000, as well as subsequent correspondence, requesting rulings on 1) the proper treatment under § 1362(d)(3)(C) of the Internal Revenue Code of rental income from the Properties, 2) the proper owner under § 1361(b)(1)(B) of Company stock held in usufruct, and 3) the effect of the early termination provision in Trust M's governing instrument (the "Provision") on the ability of Trust M to qualify under § 1361(d) as a qualified subchapter S trust (QSST).
200031037(PDF, 8K)	8/4/2000
December 26, 1999, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200031036(PDF, 10K)	8/4/2000
September 23, 1999, and a supplemental letter dated February 16, 2000, submitted by A's authorized representative requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200031035(PDF, 10K)	8/4/2000
November 12, 1999, requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200031034(PDF, 25K)	8/4/2000
August 27, 1999, in which you requested rulings concerning the tax consequences of a proposed reformation to a charitable remainder unitrust.
200031033(PDF, 68K)	8/4/2000
Issues: (1) Whether Taxpayer's right to receive insurance reimbursements from third-party insurers, associated with liabilities for certain tort claims, was fixed in the final two of the years at issue (Years E and F).
200031032(PDF, 29K)	8/4/2000
Request for a ruling dated December 23, 1999, filed on Taxpayer's behalf by its authorized representative.
200031031(PDF, 27K)	8/4/2000
Request for ruling June 9, 1999, submitted on behalf of the State Lottery.
200031030(PDF, 29K)	8/4/2000
Issue: Whether the draft notice and accompanying form letter need to be modified to clarify that the federal tax lien does not attach to a taxpayer's post-petition property when the underlying tax liability is discharged in bankruptcy?
200031029(PDF, 8K)	8/4/2000
February 8, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200031028(PDF, 13K)	8/4/2000
Requesting rulings under § 83 of the Internal Revenue Code. On Date 1, Parent transferred its ownership interest in various entities as well as certain other assets to Subsidiary A, its newly created wholly owned subsidiary.
200031027(PDF, 7K)	8/4/2000
March 1, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200031026(PDF, 28K)	8/4/2000
June 22, 1999, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under § 29 and 702 of the Internal Revenue Code.
200031025(PDF, 54K)	8/4/2000
November 3, 1998 and subsequent conversations. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200031024(PDF, 12K)	8/4/2000
January 6, 2000, submitted by your authorized representative, requesting an extension of time, under § 301.9100 of the Procedure and Administration Regulations, for taxpayer to make an election to use the alternative cost method of accounting in conformity with the requirements of Rev. Proc. 92-29, 1992-1 C.B. 748.
200031023(PDF, 102K)	8/4/2000
Issues: (1) Should the entire transaction described below, which took the form of a notional principal contract between the U.S. parent and an unrelated foreign bank followed by the assignment of some of the contract's cash flows to two foreign subsidiaries of the U.S. parent, be recharacterized as a set of loans from the foreign subsidiaries to the U.S. parent on the ground that the transaction lacks economic substance? (2) If the transaction described below is recharacterized as a set of loans from the foreign subsidiaries to the U.S. parent, do such loans constitute an investment in U.S. property under § 956 of the Internal Revenue Code?
200031022(PDF, 17K)	8/4/2000
January 10, 2000, you requested rulings concerning the generation-skipping transfer tax consequences of the clarification of a grandfathered trust.
200031021(PDF, 10K)	8/4/2000
This responds to the memorandum dated in which the search warrant request was resubmitted in the above referenced case. By memorandum dated _______, our office declined to authorize the referral of the search warrant
200031020(PDF, 62K)	8/4/2000
Issue: Whether the Taxpayers are the prevailing party as defined in Internal Revenue Code §7430(c)(4).
200031019(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031018(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031017(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031016(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031015(PDF, 56K)	8/4/2000
Issues: Whether Corporation C is a passive foreign investment company ("PFIC") under § 1296(a) of the Code for each taxable year, commencing with Year 2 through Year 13.
200031014(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031013(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031012(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031011(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031010(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031009(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031008(PDF, 18K)	8/4/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200031007(PDF, 52K)	8/4/2000
Issue: Whether a consequence of the sham transaction and assignment of income in this case is a constructive dividend from Corporation A to its shareholders, and a capital contribution from the shareholders to Corporation C.
200031006(PDF, 14K)	8/4/2000
Issue: Whether per capita payments deposited in the Trust are taxable to minor beneficiaries of the Trust in the year(s) in which the payments are deposited or in a later year.
200031005(PDF, 59K)	8/4/2000
Issues: (1) Whether the transfer of $d by Taxpayer to Parent for the guarantee by Parent of C and D's equity contributions to G is subject to tax under § 4371 of the Internal Revenue Code. (2) Whether the business profits article of the Treaty exempts the $d transfer from U.S. taxation as "commercial or industrial profits" not attributable to a permanent establishment maintained by Parent within the United States.
200031003(PDF, 32K)	8/4/2000
Issue: (1) Whether § 119 causes Taxpayer's otherwise personal expenses for meals and lodging at Taxpayer's Hotel to be deductible expenses on the Taxpayer's federal income tax return. (2) If these personal living expenses are not deductible by the Taxpayer, whether Taxpayer is considered an employee of Taxpayer's sole proprietorship so that the value of the meals and lodging are excludable from Taxpayer's gross income under § 119 of the Code.
200031002(PDF, 9K)	8/4/2000
November 22, 1999, and subsequent correspondence, submitted on behalf of X requesting relief under § 1362(f) of the Internal Revenue Code for an invalid subchapter S election.
200031001(PDF, 8K)	8/4/2000
Issue: Are amounts expended by Taxpayer to acquire certain equipment for use in his optometry practice eligible access expenditures for purposes of § 44 of the Internal Revenue Code?
200030033(PDF, 398K)	5/1/2000
This is in response to a ruling request dated September (1) 1999 submitted on your behalf by your authorized representatives. You are seeking rulings on the federal income tax consequences of certain rental income.
200030032(PDF, 639K)	5/15/2000
A notice that benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 1999.
200030031(PDF, 199K)	4/27/2000
This letter will revoke a private letter ruling which was issued to Company A on September 17, 1997, in response to a letter ruling request dated January 3, 1997.
200030030(PDF, 199K)	4/28/2000
A ruling that it is a qualified State tuition program, operating as a savings program, exempt from federal income tax under § 529 of the Internal Revenue Code (hereafter Code ).
200030029(PDF, 267K)	4/27/2000
This is in response to your letter requesting rulings regarding the federal tax consequences.
200030028(PDF, 365K)	4/27/2000
This is in response to your letter requesting rulings regarding the federal tax consequences.
200030027(PDF, 99K)	4/26/2000
This is in reply to the letter submitted on your behalf by your legal representative concerning the proposed expansion of your convention facilities to include guest quarters to be used by individuals attending your conferences.
200030026(PDF, 220K)	4/26/2000
A ruling on the application of § 4942 and 4945 of the Internal Revenue Code with respect to a proposed grant to S to support a pervasive computing research project (the Project ).
200030025(PDF, 325K)	2/25/2000
Requesting advance approval of your grant making procedures under § 4945(g)(l) of the Internal Revenue Code.
200030023(PDF, 14K)	7/27/2000
Issue: The first question you ask is if a married taxpayer who files as head of household itemizes his or her deductions, may the taxpayer's spouse claim the full standard deduction for married taxpayers filing separately? The second question is if the spouse who files as married filing separately elects to itemize deductions, may the spouse who files as head of household claim the standard deduction for head of household status?
200030022(PDF, 43K)	7/27/2000
Issues: (1) Is a married filing separate return that reflects a community split of income presumptively correct? (2) Does the Service have to establish that § 66(b) applies? (3) Where § 66(b) is asserted, should it be clearly reflected in the notice of deficiency?
200030021(PDF, 10K)	7/27/2000
December 17, 1999, requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200030020(PDF, 12K)	7/27/2000
December 28, 1999, and subsequent correspondence, submitted on behalf of X requesting relief under § 1362(f) of the Internal Revenue Code.
200030019(PDF, 17K)	7/27/2000
September 30, 1999, and subsequent correspondence, submitted by you on behalf of X, A, and Trust, requesting certain rulings concerning the federal income and estate tax consequences of the creation of Trust.
200030018(PDF, 17K)	7/27/2000
September 30, 1999, and subsequent correspondence, submitted by you on behalf of X, A, and Trust, requesting certain rulings concerning the federal income and estate tax consequences of the creation of Trust.
200030017(PDF, 10K)	7/27/2000
March 16, 2000 requesting that we rule on certain federal income tax consequences of a transaction.
200030016(PDF, 22K)	7/27/2000
January 21, 2000 requesting that we rule on certain federal income tax consequences of a transaction.
200030015(PDF, 22K)	7/27/2000
March 16, 2000 requesting that we rule on certain federal income tax consequences of a transaction.
200030014(PDF, 42K)	7/27/2000
April 27, 1999, and subsequent correspondence submitted by you on behalf of A and B, as A and B's authorized representative, requesting certain rulings under the Internal Revenue Code.
200030013(PDF, 18K)	7/27/2000
Date A in which you requested a ruling on behalf of Taxpayer with respect to contracts labeled Form B (the "Contracts"). Taxpayer requests that the Service rule as to the amount includible in gross income upon certain distributions made from the Contracts after the annuity starting date.
200030012(PDF, 18K)	7/27/2000
December 2, 1999, and subsequent correspondence, requesting rulings on behalf of Spouse, Child 1, Child 2, and Child 3 regarding the application of § 2518 of the Internal Revenue Code to disclaimers of interests in a trust and on behalf of Executor regarding the application of § 2056 to the division and reformation of a trust.
200030011(PDF, 13K)	7/27/2000
December 7, 1999, submitted by the executor of the Estate of Decedent requesting a ruling that concerns a disclaimer under § 2518 of the Internal Revenue Code.
200030010(PDF, 24K)	7/27/2000
December 28, 1999, as well as subsequent correspondence, submitted on behalf of M and N (the "taxpayers"), requesting various rulings on the proper treatment of the Trust under §§ 671, 2056, 2511, and 2702 of the Internal Revenue Code.
200030009(PDF, 10K)	7/27/2000
December 16, 1999, and subsequent correspondence, requesting a ruling concerning the Deferred Compensation Agreement (the "Agreement"), that Entities A, B, and C (the "Entities"), three closely related entities represented to be tax-exempt eligible employers described in § 457(e)(1)(B), have reached with Executive E and intend to meet the requirements for being an eligible deferred compensation plan under § 457(b) of the Internal Revenue Code of 1986.
200030008(PDF, 18K)	7/27/2000
April 9, 1999, and subsequent correspondence, from your authorized representative requesting rulings concerning the possible estate tax consequences resulting from the proposed modifications to twelve trusts.
200030007(PDF, 8K)	7/27/2000
December 23, 1999, requesting that we supplement our letter ruling dated September 13, 1999 (PLR-103429-99) (the "Prior Ruling"), regarding certain federal income tax consequences of a series of transactions, which included distributions of stock in Controlled by Distributing to Sub 15, by Subsidiary 15 to Subsidiary 1, by Subsidiary 1 to Common Parent, and by Common Parent to its shareholders.
200030006(PDF, 7K)	7/27/2000
January 31, 2000, requesting a ruling under § 1362(b)(5) of the Code that Corporation's S corporation election be effective as of Date.
200030005(PDF, 23K)	7/27/2000
November 30, 1999, submitted on behalf of all of the Underlying Funds, that certain expense arrangements will not result in the payment of preferential dividends by any of the Underlying Funds within the meaning of § 562(c) of the Internal Revenue Code.
200030004(PDF, 10K)	7/27/2000
December 6, 1999, for a ruling concerning the federal income tax treatment of benefits received by police officers and firefighters from the Plans that the City maintain.
200030003(PDF, 57K)	7/27/2000
Issues: (1) Whether the issuance of bonds was structured in such a manner that it was expected that the credit enhancement provider would pay the debt service on the bonds rather than the issuer. (2) Whether the credit enhancement for the bonds, which is secured by lease payments received from a United States agency, creates an indirect federal guarantee of the bonds. (3) Whether the issuance of bonds was an abusive arbitrage device that overburdened the market for tax-exempt bonds.
200030002(PDF, 19K)	7/27/2000
Issue: When applying the safe harbor method of Treasury Regulation §1.901-2A(e), should the statutory tax rate or the lower treaty rate be used in the "D" factor?
200030001(PDF, 37K)	7/27/2000
Issues: Are food and beverages provided by Taxpayer to its independent contractor representatives at national and regional meetings subject to the partial deduction disallowance of § 274(n)(1) of the Internal Revenue Code? Do the exceptions to the § 274(n)(1) partial deduction disallowance for (a) de minimis fringe benefits, or (b) recreational or social activities for employees, apply?

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2000 Chief Counsel'sWritten Determinations

2000 Chief Counsel's
Written Determinations